EA relaxes rules on incinerating Covid-19 clinical waste

The Environment Agency (EA) has released a regulatory position statement (RPS) that allows municipal waste incinerators to accept Covid-19 infectious waste without varying their environmental permits.

Published on Wednesday (15 April), the RPS provides leeway for operators of municipal waste incinerators to accept infectious waste during the Covid-19 pandemic.

The EA has already published an RPS temporarily relaxing the limits on waste storage on permitted sites, while Her Majesty’s Revenue and Customs (HMRC) has granted landfill operators ‘operational flexibility’ when calculating Landfill Tax.

The RPS sets out when municipal waste incinerators can accept Covid-19 infectious waste without varying their environmental permit. Any use of the RPS must be agreed with the EA prior to implementation.

The RPS states that only the following European Waste Catalogue (EWC) classifications may be dealt with, excluding sharps waste, such as needles:

• 18 01 03* – orange bagged and containerised infectious waste from human healthcare activities;
• 18 01 03* and 18 01 07 – yellow bagged and containerised infectious waste from human activities dual coded with non-hazardous chemicals;
• 18 01 04 and 20 01 99 – offensive hygiene wastes (human); and
• 15 02 02* – absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing, contaminated by hazardous substances (Covid-19 cleansing waste)

Incinerator operators must be able to demonstrate that the waste producer has used all other permitted options available for the waste’s treatment or incineration before accepting Covid-19 waste, as well as having a written management system for handling healthcare waste that allows operators to identify all healthcare waste accepted on site by date of arrival, original producer details and type of waste.

Operators must also ensure that they can comply with requirements for healthcare waste pre-acceptance, waste acceptance, handling and storage specified in the clinical waste guidance note, and ensure that burning additional waste types will not adversely affect emissions or residues. Periodic tests on emissions and incinerator bottom ash (IBA) composition must be carried out to confirm the absence of changes.

Healthcare waste must not be stored for longer than 24 hours before incineration, except in exceptional circumstances, in which case the EA should be notified immediately.

Those accepting Covid-19 infectious waste must submit quarterly hazardous waste consignee returns to the EA along with monthly reports to an operator’s local EA office, detailing the amounts and types of waste burned under the RPS.

The RPS will be withdrawn on 30 June 2020, after which time operators must have a permit authorising the burning of healthcare waste if they wish to continue doing so.

Healthcare PPE

The EA has also released an RPS on disposing of personal protective equipment (PPE) from healthcare workers treating patients in their own homes, allowing healthcare workers to dispose of their PPE through the householder’s normal residual waste collection.

Normally, PPE would be classed as healthcare waste (18 01 03* if infectious, or 18 01 04 if non-infectious under the EWC) and would need to be collected separately from the patient’s home by courier, or taken to an NHS England hospital for disposal.

The EA RPS allows healthcare workers to dispose of PPE through a householder’s residual waste provided they comply with the rules of the RPS.

PPE, such as aprons, gloves and masks, must follow Public Health England (PHE) guidance on cleaning and disposing of infected Covid-19 waste in the household, which includes double-bagging waste and keeping it separate from other residual waste for 72 hours before being placed in the external household bin.

The RPS will be withdrawn on 30 June 2020, though changes to PHE guidance may lead to the RPS being altered or withdrawn at an earlier date.

You can view the RPS on incineration of Covid-19 waste and the RPS on the disposal of PPE through the household residual waste stream on the EA’s website.